Do My Employees Need DOT Hazmat Training?

Many employers are aware that the U.S. Department of Transportation (DOT) requires hazardous materials (hazmat) training for “hazmat employees” who are involved with the transportation of hazardous chemicals and materials. But which employees are considered to be “hazmat employees?”

First, let me define “Hazardous Material”. Hazardous material is any item or agent (biological, chemical, radiological, and/or physical), which has the potential to cause harm to humans, animals, or the environment, either by itself or through interaction with other factors. Employers may assume that only those employees directly handling the shipping, receiving, and transport of hazardous chemicals are required to receive hazmat training. However, 49 CFR 172, Subpart H specifies that employees who perform the following tasks must receive Hazardous Materials Regulations (HMR) training:

For example, if the only hazardous material that is handled by a facility is hazardous waste that is generated by the facility and disposed of through a third party, the employer may believe that no employees are required to receive hazmat training because a third party handles the transport of the hazardous waste. However, the HMR specifies that employees who prepare hazardous materials for transportation (In this case, the employees who prepare the hazardous waste drum to be taken by the third party) must receive hazmat training.

Hazmat training must include general awareness training to familiarize employees with the HMR, function-specific training that is tailored to the employees’ responsibilities, and safety training that includes emergency response information and measures that can be taken by the employees to protect themselves from the hazards associated with the hazardous materials. Initial training must be completed within 90 days of hazmat employment and refresher training is required at least every 3 years.